Environmental Hearing Board (EHB)
What does it mean?
First, The Blending Proposal has
not been rejected.
The City still has no answer to its question,
“Specifically whether blending is allowed to eliminate overflows and to comply
with the Administrative Orders (AO).”
Why did the City
appeal to the EHB?
Two comments (outlined below), which could have been
perceived as ‘directives’ required the City to challenge or lose the ability to
challenge at a later date. If we had not
appealed, the regulatory agencies could have considered our lack of challenge
as acceptance of their comments.
planning meeting (9/12/2016) attended by the EPA, PADEP, LCA, and the City, where
a PaDEP employee stated that his understanding was that the Department
regulations prohibited blending.
Region III Consensus letter, (9/30/2016), “PADEP explained that “blending would be inappropriate”
In summary, the EHB did not decide
the blending issue; it dismissed the City’s appeal of an interpretation.
The City will likely file a PaDEP permit
application that includes blending and then await a written decision.
EPA AO Status Update Public Meeting: November 9, 2016 PowerPoint
EPA - Experts Forum on Public Health Impacts of Wet Weather Blending - Blending and Wet Weather Operations: An Engineering Perspective
US EPA Basic Information about Lead in Drinking Water
PA DEP Lead in Drinking Water
PA Department of Environmental ProtectionUS Environmental Protection AgencyLehigh County Authority
City of Allentown - 435 Hamilton Street - 610-439-5999